How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

Option: E All of the other options are just short-term tinkering.

6.37 The IAO states that it's vital to 'protect the character of settlements. A balanced strategy ... ensure that housing need was met across the district, and supported by appropriate infrastructure.'
Hullbridge has a unique identity and needs to have its settlement protected. It does not have the appropriate infrastructure to cope with any more house building. Many roads are unadopted and unsuitable for additional wear and tear from extra vehicles. The existing amenities are insufficient to cope with any additional increase to population. It is a village.

6.38 these (higher) settlements are characteristically more developed with a greater level of infrastructure and service provision than the smaller settlements, and therefore would provide more sustainable development.
I am strongly objecting to the idea that smaller settlements, such as Hullbridge, can cope with further development. It is very important to retain the open, rural character of the area and not let it merge with its neighbours. There is no infrastructure or service provision for development and no space in which to provide this.

6.40 Call for Sites on brownfield land: the land proposed for development SER1 onwards has not been previously developed and is not suitable because it is part of the Coastal Protection Belt and because it is essential in retaining the open, rural character of Hullbridge. We need to protect and enhance our environment, not destroy it.

'National policy and guidance places great weight on retaining the Green Belt; this view is reinforced in the Housing White Paper.'
Green Belt should be retained at all costs, once this goes, it is gone for ever. Please recognise this fact.

Sustainable travel is given as a choice in the IAO document with the 'potential for wider benefits for the environment through reduced congestion and air quality issues.'
People in Hullbridge can go on weekly organised Health Walks BUT these are for retired/unemployed folk who do not need to commute out of the area. The majority of residents have to travel by car or bus and train from Rayleigh station to outlying towns/cities for work. They do not have a choice.

In regard to Table 5, the settlement hierarchy as brought forward from the Core Strategy continues to reflect the most appropriate grading of the main settlements in the Rochford District area and it is supported that this hierarchy is included as part of the new Local Plan. On behalf of Southern & Regional Developments, Claremont Planning supports the hierarchy set out by Table 5 and continued prominence of key settlements such as Rayleigh and their potential for accommodating housing growth.

In regard to Paragraph 6.98, on behalf of Southern & Regional Developments, Claremont Planning further supports the notable position of Rayleigh in the hierarchy, occupying the top of the hierarchy and addressing its position as the largest town in the district area so therefore the most sustainable and accessible location for growth. This complies with the National Planning Policy Framework's core principle in promoting sustainable development and ensuring that growth is directed towards such settlements as Rayleigh ensures that plan is sound and provides effective policy guidance.

In regard to paragraph 6.43, on behalf of Southern & Regional Developments, Claremont Planning would seek to identify that this paragraph demonstrates the Council cannot find sufficient land to accommodate the OAN within existing settlement areas. Furthermore, that the Council's application of preference for previously developed land over greenfield land has contributed to the suppression of housing delivery in the last 10 years, especially in respect of large areas of the District that area designated as Green Belt and remained sacrosanct. Instead, a review of Green Belt and settlement boundaries is required to identify suitable growth locations and ensure the emerging policy will be compliant with the National Planning Policy Framework. The Framework's approach to delivering development requires that the environmental strand of sustainable development has equal standing to the economy and social considerations, but that in the planning balance the need to accommodate identified needs means that areas of the Green Belt that contribute less to its functions should be actively considered for release, whilst also realising a strategic approach to delivery of large scale development is preferable to the safeguarding of Green Belt. Given that the majority of the District outside settlements is washed over by Green Belt, release of such land is inevitable to ensure sufficient sites are identified to meet the required housing need over the new planning period. A Green Belt review is required to identify the most suitable and sustainable options for release from the Green Belt, whilst also ensuring that the overall function of the Green Belt is not compromised. This will ensure that the plan remains effective in seeking sufficient housing land, but also remaining sound in ensuring adequate protection of the environment and the Green Belt.

Table 5 of the Issues and Options Report sets out the settlement hierarchy, with the supporting text noting that the "balanced approach" adopted in the 2011 Core Strategy directed development to the higher order settlements on the basis that these settlements have greater levels of infrastructure and service provision, and so offer more sustainable locations for growth.

Although the settlement hierarchy should in our view remain the starting point for the strategy for accommodating housing and other development requirements, it does not follow that every settlement within each tier of the hierarchy should be apportioned the same amount of growth. For example, in the highest tier, Rayleigh is the largest of the three settlements, offers the widest range of services and facilities, and offers the best access to the strategic highway network.

As well as the comparative merits of individual settlements within the same tier, the development strategy will also need to consider a 'bottom up' approach to the suitability of individual development sites against local constraints, and the ability of those development sites to deliver the requisite infrastructure to support that development.

Paragraph 6.40 of the Issues and Options Report notes that the Council needs to look firstly at opportunities for development that do not involve land designated as Green Belt. We agree that optimising the use of non-Green Belt land is important, and as set out elsewhere in our representations we consider that there is scope to deliver more homes on the allocated site SER1 at Rayleigh (SHELAA site CFS167).

However, it is important to be realistic and in particular to:

(a) Acknowledge that the scale of housing need means that some Green Belt land will inevitably be required as well. For example, the reference at paragraph 6.43 to there being a lack of available land within existing residential areas "at present" to meet the need for new homes is somewhat disingenuous, in the sense that the implication is that the issue is finally balanced or that sufficient urban land might come forward in the near future, when in neither is the case;

(b) Not rely on brownfield sites that have no realistic prospect of being redeveloped for residential purposes - this includes site BFR4 (Rawreth Lane Industrial Estate), which although reassessed through the SHELAA and correctly identified as having delivery constraints, is nevertheless still apparently being considered as a residential site despite the lack of any likelihood of that occurring.

Of the 6 options set out in the Issues and Options Report under paragraph 6.48, we would comment as follows:

Option A - Increased density on infill and redevelopment sites within existing urban areas obviously makes sense, but given also the need to respect the character of existing residential areas, the limitations on such sites to deliver new infrastructure due to tight land constraints, and the need to ensure that appropriate living and amenity standards are met, naturally means that the extent to which increased density can be achieved in practice is likely to be limited. Realistically, it is not the Council's Density Policy DM2 that limits housing yield from urban sites, because the policy is expressed as a minimum anyway, it is all of the other necessary development management policies on achieving space standards, parking, amenity and basic design that serve to limit the extent to which yield can be increased within existing urban areas. Therefore whilst urban redevelopment is rightly part of the strategy, ultimately dwelling provision from such sources will only make a small contribution to meeting the overall housing requirement.

Option B - Increasing density on existing allocated residential sites is fully supported, but clearly in some cases that will no longer be possible where the development is already far advanced, or appropriate in those locations where additional housing above the existing allocation would not be possible. Site SER1 to the west of Rayleigh (SHELLA sitet CFS167) represents a scenario where this would clearly represent sound planning due to the low density of the original proposal and the planned on-site infrastructure which would have spare capacity to accommodate additional homes. Where land has already been removed from the Green Belt under the currently adopted Core Strategy and Site Allocations Plans, and that land can deliver more housing, it makes no sense to release more land from the Green Belt until the effective yield from these existing allocated but un-built sites has been properly maximised.

Options C and D - It is likely that the development strategy will require both smaller scale and larger scale greenfield/Green Belt developments to meet the level of housing need, but the Issues and Options paper rightly notes that it is the larger sites that have the greater ability to provide for new infrastructure to support development, both on-site (for example, the delivery of new education facilities on site) and off-site through effective travel measures and investment in the highway network, meaning that larger sites offer the greater benefits.

In terms of specific development options, we would commend the following:

* Securing additional development on that land currently allocated and granted outline permission to the west of Rayleigh, north of London Road, otherwise known as site SER1/SHELAA site CFS167. The consented proposals for this site already include for investment in substantial new infrastructure, including the central spine road that will serve the development parcels, the provision of substantial areas of parkland open space alongside specific facilities such as allotments and sports provision, and the construction of a new health centre and primary school. Locating additional development where it can maximise access to, and use of, this existing planned infrastructure will ensure that new development here does not place a strain on infrastructure elsewhere.

The Council will also be aware that the consented density of development on site SER1 is relatively low, and that there is therefore potential both to increase density within the already consented residential parcels, and to provide appropriate extensions to those parcels, without materially impacting on the overall strategy for extensive green infrastructure provision or materially altering the character of the development.

In accordance with the 'call for sites' information submitted to the Council previously, the site could accommodate around a further 150 residential units in addition to the 500 units previously granted (i.e. 650 in total within the site of Outline permission 15/00362/OUT, excluding homes also provided at Timber Grove and the paddocks south of the sports field that also form part of SER1), and can achieve this using the same strategies for transportation and drainage as per the existing Outline permission, and well within the capacity of the on-site health and education facilities.

As the Council will be aware, under the current adopted Core Strategy and Site Allocations Plan, the combination of SER1 and the adjoining Rawreth Industrial Estate site (BFR4) were together intended to deliver around 775 homes in the Plan period, but in the absence of any practical likelihood of site BFR4 coming forward for development, there is already a shortfall in delivery in this part of Rayleigh compared to expectation, and increasing yield from SER1 would contribute towards remedying this deficiency.

* Further expansion of Rayleigh to the west utilising SHELAA sites CFS146, and 147.

This area of land, lying between London Road, Rawreth Lane and the A1245, offers the opportunity to provide additional development in a location that can make best use of the health, education nd green infrastructure to be provided as part of the adjoining SER1 allocated site. As with intensification within the SER1 site, development to the west in this same location shares the same benefit of enabling best use to made of existing and planned infrastructure, to ensure that new development does not result in pressure on existing services elsewhere.

The broad strategy for development can follow the same principles established by the SER1 development, such as a buffer of green infrastructure to the western boundary to maintain appropriate separation to both Rawreth and the A1245, an east-west running central green space to avoid the flood plain to the Rawreth Brook and provide a strong framework for open space and landscaping, and a linked public transport strategy providing access by non-car modes to the centre of Rayleigh and the railway station, alongside access to on-site social and community facilities. It may also be possible to extend development to include land north of London Road in this location (e.g. SHEELA site CFS148).

Although it is anticipated that construction of the adjoining SER1 site will begin shortly, the fact that the adjoining allocation has not yet been completed provides an opportunity to ensure that both the original and extended allocation could, if supported by the Council, be developed to common Masterplanning principles, to produce a cohesive and well-designed urban extension to Rayleigh, alongside the requisite investment in infrastructure required to support the enlarged proposal.

Delivering the need for new homes

Table 5 identifies the proposed settlement hierarchy for the District and which identifies;

Tier Settlements
1 Rayleigh; Rochford/Ashingdon; Hockley/Hawkwell
2 Hullbridge; Great Wakering
3 Canewdon
4 All other settlements

GVA consider that development within the District should be located where it is accessible to a range of transport options and where new housing is able to be served by sufficient community facilities to meet the needs of residents. We would support focusing development on the most sustainable settlements and in this respect consider that the Tier 1 and 2 settlements would in effect be the only locations where new housing could be located in any quantum.

In this respect, the Tier 3 and 4 settlements do not offer a suitable range of facilities to meet the need of new residents and consequently locating new development in these settlements, other than in a limited format which would lead to unsustainable pattern of development contrary to the wider Plan vision and national policy

Rochford district is at gridlock because of bad planning over a number of years. The housing policy across the whole country is flawed. Lobbying by large house builders and media scare stories of a housing crisis has lead to a knee jerk reaction by government which has resulted in hundreds of soulless communities being built with all profit going to large corporations. This rush to build at all costs has meant the wrong type of housing has been built as house builders will always go for maximum profit. Therefore a lot of four and five bedroom properties have been built instead of affordable homes. Also, in this area there are a lot of people aged sixty plus who probably would have downsized but new properties have not been built with that age group in mind. Older housing stock has usually been extended. Sadly the majority of these houses have not been built with sustainability in mind i.e. solar panels and heat exchange systems, this truly is inexcusable.
It is now imperative that a more sustainable house program is planned. The target for the next twenty years should be closer to three thousand properties which works out at approximately one hundred and fifty a year. There should be a thorough review of what type of properties are required. These should then be built by local builders on much smaller sites which involve between ten to twenty properties so as not to totally overwhelm an area. There must be no more large building sites as this area's roads and infrastructure cannot cope with the population it already has. The quality of life of residents has suffered tremendously from bad planning decisions and if this continues I can see it leading to poor mental health.
Some of the proposed sites should not be built on at all they are:- 1. Belchamps scout camp, this is an educational site with good public transport links (I will be writing to the scouts to let them know how disappointed I am that they have proposed their site. Better ethics are required from people who are educating our future generations).
2. Farmland next to Mount Bovers Lane. We should not be building on anymore farmland. This is also an important visual amenity. To have potentially six hundred and sixty houses on this site means in the region of approximately one thousand three hundred and twenty cars all going on to the already gridlocked main road.
3. Nursery Corner and plot of farmland running down the main road to the B1013 Cherry Orchard Way roundabout. Building on farmland is unacceptable. Cherry Orchard was built as a relief road to relieve the already congested roads, the building that has taken place around here should never have been allowed. No more development should be allowed around Cherry Orchard.
4. Ark Lane to the Cherry Orchard Country Park, the same reasons as above. The council will lose all credibility if it allows anymore development around a road that was built as a relief road.
5. Ashingdon Road is already very congested so any proposed sites whose access is onto the Ashingdon Road should be refused. Any farmland in this area and the Brays Lane area should not be built on.
6. Meadowbrook Farm which is at the end of Ironwell Lane should have no development as it is also farmland.
Why have Rochford District Council put Hockley and Rayleigh car parks forward? I am struggling to think where else Hockley could have a car park. If there is a plan, residents should have been notified first.
It is now imperative that before new sites are released, all existing sites with planning permission are developed first, so it can be monitored how roads and infrastructure are coping.
Any new sites should be brownfield. Hockley high street could also be much better utilised as there is scope to have shops with flats above.

Thank you for the opportunity to comment on the Rochford Local Plan Issues and Options consultation document. The following response is submitted on behalf of Anglian Water as sewerage undertaker for Rochford District.

I would be grateful if you could confirm that you have received this response.

Tell Us More: What do you think the new Local Plan should be trying to achieve, and why?

We are supportive of Draft Strategic Objective 13 which relates to Anglian Water's water recycling infrastructure but would ask that the Local Plan policies expands on this issue and emphasises the use of sustainable drainage systems (SuDS) as the preferred method of surface water management and that the timing of development is aligned with sufficient water recycling infrastructure. (Please see comments relating to Question SP3.4 and SP3.6).

Tell Us More SP1.3: How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

Six potential options or a combination of the available options are identified as being a realistic strategy for the delivery of new homes. We would welcome further discussion with the Council about the distribution of additional housing and the implications for Anglian Water's existing infrastructure and the extent to which there is a need for new or improved infrastructure.

Tell Us More SP3.4: How do we address water and flood risk management over the next 20 years?

Reference is made to principal risks of flooding being from rivers, the sea and surface water within the district but not the risk of flooding from sewers. We would ask that the new Local Plan includes a specific policy on flood risk and water management which includes the following requirements:

* Applicants to demonstrate that capacity is available within the public sewerage network and receiving water recycling centre (formerly sewage treatment works) in Anglian Water's ownership or can be made available in time to serve the development.
* Sustainable Drainage Systems (SuDS) to be identified as the preferred method of surface water disposal and that it is considered as part of the design of new developments and re-developments. The policy should also ensure that applicants provide evidence as part of the planning application that they have followed the surface water hierarchy as outlined in the National Planning Practice Guidance. With surface water connections to the public sewerage networks being allowed only on an exceptional basis where alternatives are shown to be technically unfeasible.
* That suitable access is safeguarded for the maintenance of existing drainage infrastructure following development.

Reference is made to a recommendation on the Council's Environmental Capacity Study that the existing Water Cycle Study published in 2011 should be updated. In the event that the District Council is intending to commission an updated Water Cycle Study we would welcome further discussion with the District Council about the scope of any technical work. We are currently preparing a Water Recycling Long Term Plan currently being prepared which will set out Anglian Water's long term strategy for water recycling centres and sewerage catchments and is expected to be published in Summer 2018.

We would welcome further discussions with the Council relating to any further technical work relating to water recycling infrastructure which is to be commissioned following the preparation of the Outline Water Cycle Study.

Tell Us More SP3.6: How do we deal with planning obligations and standard charges to support the delivery of new homes and jobs over the next 20 years?

The focus of this question is on the use of planning obligations and standard charges to provide infrastructure to support the delivery of development within the district. Anglian Water as a sewerage company seeks charges directly from developers under the provisions of the Water Industry Act 1991 as such we would not make use of planning obligations or standard charges under Planning Legislation for this purpose. Further information relating to the charges which will come into effect from 1st April 2018 is available to view at the following address:

http://www.anglianwater.co.uk/developers/charges/

However we would ask that any Local Plan policy relating to planning obligations/standard charges also emphasises the need for phasing and the use of planning conditions/obligations to ensure development is aligned with the provision of infrastructure for this purpose. Therefore we would ask that the following wording or similar be included in the Local Plan:

'Consideration must be given to the likely timing of infrastructure provision. As such, development may need to be phased either spatially or in time to ensure the provision of infrastructure in a timely manner. Conditions or a planning obligation may be used to secure this phasing.'

We would welcome further discussion with the District Council relating to the wording of the Local Plan policies relevant to Anglian Water prior to the next formal stage of the preparation of the Local Plan.

This letter provides Gladman Developments Ltd (Gladman) representations in response to the Issues and Options consultation for the New Rochford Local Plan. Gladman specialise in the promotion of strategic land for residential development with associated community infrastructure and welcome the opportunity to comment at this early stage of the plan preparation. We look forward to assisting the Council and hope our comments are helpful and considered constructively to aid the development of a sound plan.
Gladman has considerable experience in the development industry in a number of sectors including residential and employment development. From that experience, we understand the need for the planning system to provide local communities with the homes and jobs that they need to ensure that they have access to a decent home and employment opportunities.
Gladman also has a wealth of experience in contributing to the Development Plan preparation process, having made representations on numerous local planning documents throughout the UK and having participated in many local plan public examinations. It is on the basis of that experience that the comments are made in this representation.
The National Planning Policy Framework sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
* Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
* Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base;
* Effective - the plan should be deliverable over its period and based on effective joint working on crossboundary strategic priorities; and
* Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
The White Paper and Revised NPPF
The Government White Paper ('Fixing our Broken Housing Market') issued in February 2017 is a very clear statement from Government on the importance of the delivery of housing to the wider economy. The Government are in no doubt
that the housing market in Britain is broken which, according to the Prime Minister, is one of the greatest barriers to progress in the country today. Average house costs are almost eight times average earnings which is an all-time record and soaring prices and rising rents caused by a shortage of the right homes in the right places has slammed the door of the housing market in the face of a whole generation. The reason for this crisis is that the Country is simply not building enough homes and has not done so for far too long. The consensus is that we need from 225,000 to 275,000 or more homes per year to keep up with population growth and to start to tackle years of under-supply.
Everyone involved in politics and the housing industry therefore has a moral duty to tackle this issue head on. The White Paper states quite unequivocally that 'the housing shortage isn't a looming crisis, a distant threat that will become a problem if we fail to act. We are already living in it.' Tackling the housing shortage is not easy. It will inevitably require some tough decisions. But the alternative, according to the White Paper, is a divided nation, with an unbridgeable and ever-widening gap between the property haves and have-nots. The challenge of increasing supply cannot be met by government alone. It is vital to have local leadership and commitment from a wide range of stakeholders, including local authorities, private developers, housing associations, lenders and local communities. The starting point is building more homes. This will slow the rise in housing costs so that more ordinary working families can afford to buy a home and it will also bring the cost of renting down. We need more land for homes where people want to live. All areas therefore need a plan to deal with the housing pressures they face.
Currently, over 40 per cent of local planning authorities do not have a plan that meets the projected growth in households in their area. All local authorities should therefore develop an up-to-date plan with their communities that meets their housing requirement based upon an honest assessment of the need for new homes.
Local planning authorities have a responsibility to do all that they can to meet their housing requirements, even though not every area may be able to do so in full. The identified housing requirement should be accommodated in the Local Plan, unless there are policies elsewhere in the National Planning Policy Framework that provide strong reasons for restricting development, or the adverse impacts of meeting this requirement would significantly and demonstrably outweigh the benefits. Where an authority has demonstrated that it is unable to meet all of its housing requirement, it must be able to work constructively with neighbouring authorities to ensure the remainder is met.
Plans should be reviewed regularly and are likely to require updating in whole or in part at least every five years. An authority will also need to update their plan if their existing housing target can no longer be justified against their objectively assessed housing requirement. Policies in Local Plans should also allow a good mix of sites to come forward for development, so that there is choice for consumers, places can grow in ways that are sustainable, and there are opportunities for a diverse construction sector including opportunities for SME housebuilders to deliver much needed housing.
In terms of rural areas, the Government expects local planning authorities to identify opportunities for villages to thrive, especially where this would support services and help meet the need to provide homes for local people who currently
find it hard to live where they grew up. It is clear that improving the availability and affordability of homes in rural areas is vital for sustaining rural communities, alongside action to support jobs and services. There are opportunities to go further to support a good mix of sites and meet rural housing needs, especially where scope exists to expand settlements in a way which is sustainable and helps provide homes for local people. This is especially important in those rural areas where a high demand for homes makes the cost of housing a particular challenge for local people.
Finally, the Government have made it clear through the White Paper that local planning authorities are expected to have clear policies for addressing the housing requirements of groups with particular needs, such as older and disabled
people.
The White Paper is the cornerstone of future Government policy on fixing the broken housing market. It provides the direction of travel the Government is intending to take and is a clear statement of intent that this Government is serious
about the provision of the right number of houses in the right places. The Local Plan therefore needs to consider these policy intentions now in order to ensure that it fulfils the Government's agenda and provides the homes that its local communities need.
Following the election, Sajid Javid re-iterated the Government's intentions for boosting housing growth stating that he wants areas that have benefitted from soaring property prices to play their role in solving the housing crisis. Mr Javid
pointed out that where property prices were particularly unaffordable, local leaders would need to take a long, hard and honest look to see if they are planning for the right number of homes. Consultation on the new proposed standardised methodology for calculating housing need took place in late 2017. This has now been followed by consultation on a revised NPPF, which opened on the 5th March. The Council should therefore be very mindful of the changes this will entail to the plan preparation process to ensure the requirements of the new NPPF will be met when the final version is published and implemented later this year. Many of the changes consulted on in the Housing White Paper will be brought forward in the revised NPPF and this will assist the Council in determining its preferred options and also housing requirement as the plan preparation progresses.
Duty to Cooperate
The Duty to Cooperate is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. It requires local authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of Plan Preparation. If a Council fails to satisfactorily discharge its Duty to Cooperate, this cannot be rectified through modifications and an Inspector must recommend non-adoption of the Plan.
Whilst Gladman recognise that the Duty to Cooperate is a process of ongoing engagement and collaboration, as set out in the PPG it is clear that the Duty is intended to produce effective policies on cross boundary strategic matters. In
this regard, the Council must be able to demonstrate that it has engaged and worked with its neighbouring authorities, alongside the existing joint work arrangements, to satisfactorily address cross boundary strategic issues, and the
requirement to meet any unmet housing needs. This is not simply an issue of consultation but a question to ensure that the Housing Market Area's (HMA's) housing needs are met in full. Failure to satisfactorily discharge the duty to cooperate cannot be rectified by modifications and a Planning Inspector
must recommend non-adoption of the plan. An issue familiar within the Housing Market Area following Castle Point's withdrawal of its Local Plan after a failure to satisfactorily discharge the Duty to Cooperate. The revised NPPF will require
a statement of common ground between authorities within the HMA which would require the updating of the current memorandum of understanding between the authorities. This document currently lacks any certainty that housing needs will be met within the HMA and this will require clarification moving forward.
Sustainability Appraisal
In accordance with Section 19 of the Planning and Compulsory Purchase Act 2004, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA),and also incorporate the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations).
The SA/SEA is a systematic process that should be undertaken at each stage of the Plans preparation, assessing the effects of the emerging proposals on sustainable development when judged against all reasonable alternatives. The Council should ensure that the future results of the SA clearly justify its policy choices. In meeting the development needs of the area, it should be clear from the results of this assessment why some policy options have progressed and others have been rejected. This must be undertaken through a comparative and equal assessment of each reasonable alternative, in the same level of detail for both chosen and rejected alternatives. The Council's decision making and scoring should be robust, justified and transparent.
Objectively Assessed Need
Gladman are concerned that the realistic options that have been identified for establishing the Objectively Assessed Needs and housing requirement for the plan are not actually realistic options and instead Options A and B are fundamental requirements for the plan making process whilst there is no sound basis for following option C.
Until the formal publication of the Government's standardised approach to assessing housing needs is published and implemented Gladman would suggest using the approach as established in the South Essex SHMA. This is currently considered to be a sound basis for assessing housing needs, with the upper range of the Objectively Assessed Need (OAN) for Rochford being a very similar figure to the standard methodology as currently proposed. Gladman suggest that this upper figure is aimed for now to reduce delay later in the plan preparation process. Whilst the Council are right to consider constraints on development within the Borough, environmental capacity should not be the sole reason for reducing its housing requirement. This is only one dimension of sustainable development and the Council should consider the social and economic benefits of housing delivery and whether these would outweigh the negative environmental impacts. Further, mitigation of these environmental impacts should be a consideration before deriving at the decision that the environmental capacity would not enable the delivery of full
objectively assessed housing needs. Should it be established that the Council cannot meet its own housing requirements this will require collaboration with
authorities in the HMA to ensure that these needs do not go unmet.
Affordable Housing
Gladman would suggest the use of a viability assessment to establish the level of affordable housing that will be sought in the Borough in the plan period. This should be at a level that does not affect the viability of development or push it to the margins. Until a viability assessment has been undertaken it is not possible to determine the correct approach to the level of affordable housing that should be provided. The level of affordable housing that development can reasonably support will vary in relation to the infrastructure required, the nature of the development strategy being taken forward and other policies in the plan, such as the optional technical standards.
Specialist Accommodation, Homes for Older People and Adults with Disabilities
The provision of specialist housing to meet the needs of older people is of increasing importance and the Council need to ensure that this is reflected through a positive policy approach within the Local Plan. The Councils need a robust understanding of the scale of this type of need across the Borough.
Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own self-contained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide internally
accessible communal facilities including residents' lounge, library, dining room, guest suit, quiet lounge, IT suit, assisted bathroom, internal buggy store and changing facilities, reception and care managers office and staff facilities.
Given the existing evidence in relation to ageing populations, and the national strategy in relation to housing for older people, Gladman recommend that the new Local Plan should include a specific policy in relation to the provision of specialist accommodation for older people. The following text provides an example of the type of policy which could be included in the new Local Plan:
"The provision of purpose built and/or specialist accommodation with care for older people in sustainable locations will be supported in Principle Settlements. Schemes should also be considered in other sustainable settlements where there is a proven need. Apartments should be restricted for occupation by only those with care needs, include minimum compulsory care packages, should also include age restrictions and an extensive range of communal facilities.
Schemes are expected to be promoted in partnership with an onsite 24/7 care provider to safeguard the delivery of care and support to residents.
Such schemes fall wholly within the auspices of C2 use, meet an otherwise unmet need for specialist accommodation for older people, deliver care and communal facilities and will not therefore be required to contribute towards affordable housing."
Delivering New Homes
Gladman suggest that a mix of options will be needed to ensure the delivery of the spatial strategy and housing requirement. To maximise housing supply the widest range of sites, by size and market location, are required so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products.
The key to increased housing supply is that number of sales outlets. A wider variety of sites in the widest possible range of locations ensures all types of house builder have access to suitable land which in turn increase housing delivery.
Good Mix of Homes
Gladman do not consider it appropriate to set a target for the development of bungalows. Bungalows will have a much larger footprint than two and three-story homes of the same floor area and as such have a significant impact on viability
due to the reduction in the number of units that can be delivered on a site. The Council must also remember that there is a need to maximise development on each site and the delivery of bungalows will significantly reduce the capacity of each site. This will require the Council to release more land or set higher density targets than the 30 dwellings per hectare, as identified as an option on page 50, if it is to meet housing needs.
Green Belt
Gladman urge the Council to undertake a full review of the Green Belt within the Borough to identify areas that are no longer meeting the five purposes of Green Belt as set out in the Framework. Once established these areas should be considered for release from the Green Belt to help meet the OAN for the Borough. Without having undertaken this work the Council will not be able to justify not meeting its own needs, especially if other authorities indicate they will not be
able to help Rochford meet any unmet needs.
Conclusions
We hope you find these comments helpful and if you require clarification on any of the issues raised in this letter please contact me. If you could add me to your mailing list for the new Local Plan and any supporting documents I would be most grateful.

On receiving the correspondence regarding "Future Housing Development" On plot accessed off Barling Road and situated between Smithcroft Bungalow on the left and Claystreet on the right, I am writing my objections to this site being the proposed site for building application. We live in a small hamlet, not a village. We have no immediate services. There is not even a bus service on Sundays. Since moving here approximately ten and a half years ago the traffic along this narrow B road (Barling Road) has increased 5-fold avoiding the amount of cameras on the Artillery Way A1159 leading onto Eastern Ave, Priory Crescent and ending up on the A127. We already get heavy lorries coming round this way going to the Purdeys Industrial Estate. We get five times the amount of private cars and have always had the farm vehicles. Right through this hamlet there are no suitable pavements for the elderly and children to walk along even to visit the post box. Looking at the proposed plans the entrance to this building site is onto Barling Road in between two existing properties, thereby this will increasing the load on this narrow B road yet more.

These plans will block our current views which you will appreciate is why we brought the property we did and have made extensive improvements to it. It will de-value our properties as the plans come right up to the current back border of our property.

I am disabled and we are both in our mid-seventies with no chance of getting a mortgage. It was a builder who left us penniless after trying to increase the price of the renovations and we are now with a charity Money Finance firm getting straight. So we will not be able to move on from our final expected permanent home to retire in.

There are all the buildings on Victoria Avenue just rotting. Opposite the Police Station and Law Courts, please tell me why these cannot be knocked down and the more than average square footage used to build more affordable houses.

There will be a lot more of these spaces to use where firms have given up their leases and properties. Why not build on the current built up areas that have become derelict instead of using greenbelt land. Nobody would object to one school with sports grounds surrounding it as more schools are definitely needed and the green sports grounds would also fit in with the area. The traffic would only be school runs.

Please considered my views as we love where we live as do our neighbours. I am quite sure if the members of the Council were faced with the prospect of their lives being disrupted as all ours will be they would also be purturbed.